Section 327(2) provides that an exempt professional firm must be a member of a profession or be controlled or
managed by one or more members. 3The FCA considers that "managed"
here should be read with its natural meaning. However, it may not be sufficient
for a compliance manager to fulfil the role of manager, unless that individual
is also able to exercise significant management functions involving overall
oversight of the operation/business of the relevant person.

The FCA considers that to satisfy the
condition in section 327(4) regulated activities cannot
be a major part of the practice of the firm. The FCA also considers the following further
factors to be among those that are relevant: